Corrective Action Plans

November 18, 2025 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 The PATH School already has or will take the following actions to address the FY2025 supplemental audit report comments: Required Reports 1. We will implement additional procedures and internal controls to ensure that all required student documentation is consistently collected and maintained. As part of these enhanced controls with our front office staff including receptionist and office manager, our enrollment process now includes a mandatory step requiring all students to complete the Free/Reduced Lunch Application on an annual basis. This will be implemented immediately. This measure will help ensure accurate reporting and compliance with program requirements. Sincerely, Theodore Brannum Chief Operations Officer E: tbrannum@thepathschool.org

Management Response: Feeding South Florida complied with LFPA contract provisions for food purchases by meeting and invoicing the required food purchase minimum. Freight was an allowable cost for the contract. Despite miscategorizing 5 freight invoices, Feeding South Florida complied with the LFPA contract for freight by meeting and invoicing the total amount allowable for freight. To ensure ongoing compliance, we established and implemented a comprehensive Standard Operating Procedure (SOP) for all contracts and grants, including the LFPA program, which has been consistently followed since LFPA Plus began. To strengthen oversight and enhance audit readiness, administrative responsibility for this contract has transitioned from the Grants Department to the Finance Department. This restructuring reinforces our compliance framework, improves operational support, and embeds stronger accountability measures across all organizational levels and throughout our region.

Condition and Context: During our audit of the Public Safety Partnership and Community Policing Grant (CFDA 16.710), we were unable to obtain a copy of the required SF-425 (Federal Financial Report) submitted by the County. Recommendation: We recommend that the County implement procedures to ensure that copies of all required federal reports are retained in accordance with federal record retention requirements and made available for audit purposes. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish procedures to ensure that all required federal reports are retained and readily available for future monitoring and audits.

1. Documentation Recovery — Completed (September 2025) ○ Contacted vendors to obtain duplicate invoices and receipts for all transactions with missing documentation. 2. Current Transaction Review — Completed (October 2025) ○ Conducted a comprehensive review of all pending and recent transactions. 3. Documentation Requirements Policy — Completed (September 2025) ○ Corrected identified gaps and implemented a Pending Documentation File system to track incomplete transactions. ○ Prepared expense memoranda describing goods/services, business purpose, and program benefit for any unrecoverable items. ○ Organized all recovered documentation into auditable files for review. ○ Establishes documentation standards for all expenditures. ○ Implements enhanced requirements for federal awards in compliance with 2 CFR §200.302 and § 200.303. ○ Requires submission of receipts/invoices within five (5) business days. ○ Aligns retention and compliance standards with federal and state regulations. ○ Defines clear consequences for non-compliance. 4. Strengthened Documentation Controls — Completed (October 2025) Purchases over $500 require prior written approval. ○ All receipts must be submitted within five (5) business days of the transaction. ○ Missing documentation triggers a 48-hour follow-up hold on spending authorizations. ○ Monthly certifications confirm all transactions are fully supported. 5. Enhanced Federal Award Documentation — Completed (October 2025) ○ Implemented a federal expenditure checklist requiring itemized receipts, program benefit descriptions, budget references, and authorizing signatures. ○ The Finance Director conducts monthly reviews of all federal expenditures. 6. Staff Training — Completed (October 2025) ○ Conducted mandatory training on documentation standards, federal compliance, and allowable costs under 2 CFR Part 200. ○ Training materials added to new employee orientation with annual refreshers scheduled. 7. Ongoing Monitoring — Ongoing ○ Monthly sample audits conducted by the Finance Director to verify compliance. ○ Quarterly reporting to the COO summarizing documentation metrics. ○ Annual compliance results presented to the Board Finance/Audit Committee.

Management has reinforced the effective execution of existing controls around proper documentation of all expenditures and record retention for these expenditures. Monthly and year-end procedures have been updated to ensure compliance with these procedures. Anticipated completion date: June 30, 2025.

Name of Contact Person: Grace Leatherman – Executive Director Contact Information: 410-440-9066 Corrective Action Plan: Finding 2024 – 002 Management is in agreement with the findings and will remind staff to include supporting calculations when submitting for reimbursement per Organization policies. Senior staff will review payroll data to ensure calculations are being made and reported. Expected Completion Date: The Organization expects all findings to be resolved by December 31, 2025

Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support program activities and reports submitted to the grantor. All staff charged with maintaining client documentation will receive updated training on recordkeeping requirements, supporting documents specifying such requirements, and supports throughout the year to ensure documents are properly maintained and verified. Documents will be reviewed regularly for completeness and specifically cross-checked with quarterly report and invoice information directly by program leadership prior to submission. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

anagement agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. All program staff will receive updated training on eligibility requirements, supporting documents to track such requirements, and supports throughout the year to ensure eligibility requirements are met and documented. Documents will also be reviewed regularly to ensure completeness against eligibility requirements. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom pliant with federal procurement standards. Since the policy adoption, all new procurements have followed the updated procedures. The organization also did not keep records of debarment search results. • What's been done: All procurement following the adoption of the procurement policy has been done in alignment with the policy. We also introduced procurement "kickoff meetings" for new grants to review each budget line, determine the correct procurement method, and plan documentation for the procurement process. This has been piloted with our most recent grant. All vendors now have debarment searches in their QuickBooks vendor information tab. • Next steps: Apply this process to all new grants to ensure compliance from the outset. • Responsible party: Finance manager and Executive Director of Michigan Center for Adult College Success with oversight by President

Finding 2024-002 Finding Subject: Economic Development Cluster – Reporting Summary of Finding: Material Weakness, Other Matters The data submitted in the SF-425 report submitted by the city for the reporting period ending on 9/30/24 contained the following errors: • Cash Receipts Understated by $1,037,155 • Cash Disbursements Understated by $1,037,155 The lack of internal controls and noncompliance was isolated to the award 06-79-06420 EDA-Davis Road Construction project. Contact Person Responsible for Corrective Action: Weston Reed Contact Phone Number and Email Address: 765-456-7380 wreed@cityofkokomo.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: City of Kokomo will design and implement a procedures where the Federal Financial Report and the Quarterly progress report will be reviewed by the director of development to ensure that there is oversight and that the report is complete and accurate. Anticipated Completion Date: December 31, 2025

Federal program title: Home Partnership Investment Program, and Local Assistance and Tribal Consistency Fund program CFDA 14.239, 21.032 Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This process should ensure that key documents are securely stored, easily accessible, and periodically reviewed to support ongoing compliance with grant requirements. Additionally, the County should work with granting agencies to obtain copies of any missing agreements and perform a comprehensive review to identify and address any outstanding compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Completed and on-going.

2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A process for retaining claims and supporting documentation has been implemented.

Tuerk House, Inc. recognizes the importance of maintaining compliance with federal grant requirements related to allowable costs and documentation standards. The Organization acknowledges the deficiencies identified in the areas of time and effort reporting and supporting documentation for expenditures charged to grant programs. To address this finding, Tuerk House is taking the following corrective actions: ·Implementing a formal time and effort certification process that requires employees to certify actual time worked on federal grant activities on a regular basis, rather than relying on budgeted allocations. ·Developing a standardized cost allocation methodology that aligns with actual grant activity and is supported by verifiable documentation. ·Requiring that all expenditures charged to federal awards be supported by complete and accurate source documentation, including vendor invoices, timesheets, and approvals. ·Establishing a document retention policy consistent with 2 CFR § 200.334 to ensure all supporting records are retained for the required period and readily accessible for audit or review. Training sessions for program and finance staff will be conducted to ensure consistent understanding and application of these updated policies and procedures. Organization Contact Person Responsible for Corrective Action – Joseph Koehler, Director of Finance Anticipated Completion Date – June 30, 2025

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period. This includes quarterly reports, expense reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs.

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide several critical documents required to support its eligibility and compliance under the MTW framework: 1. The Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements. 3. The Authority did not provide the required supplement to the annual MTW Plan, which outlines planned uses of MTW funds and activities for the fiscal year. 4. The Authority also failed to provide the HUD-issued approval letter for the supplement to the annual MTW Plan, which is necessary to validate HU D's acceptance of the Authority's proposed activities.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC, required supplement to the annual MTW Plan, the HUD issued approval letter for the supplement to the annual MTW Plan, and to complete the MTW Certification of Compliance.

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide two critical documents required to support its eligibility and compliance under the MTW framework: he Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority also failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC and to complete an MTW Certification of Compliance.

Finding 2024-002 Bridges Interface Controls Management Views DTMB disagrees with the condition and the effect of the OAG’s finding. The OAG sampled 85 total files across eight interfaces. Of these, seven appeared to present issues. For five of the sampled files, detailed exception results no longer existed. DTMB maintains summary tables for 10 years and purges detailed exception records at the beginning of each calendar year for anything older than 12 months. This purge process was communicated to the OAG during the fiscal year 2022 audit, and sampling was performed prior to purging for the fiscal year 2023 audit. When informed that the sample included files for which the detailed exception records had been purged, the OAG requested DTMB run a simulation processing of the original interface file in a testing environment to recreate detailed exception records. DTMB’s technical teams informed the OAG that rerunning in the current test environment would likely differ from the original results due to code changes that occurred in the test environment subsequent to when the original interface files were run in production. The OAG requested DTMB to proceed with rerunning the files in the current test environment. As a result, the OAG identified five instances where the detailed exception records from the simulation in the test environment did not exactly match the summary table from the original production interface results. For the 2 remaining files out of 85 (2.4 percent) that were cited, it should be clarified that the reconciliation being discussed is not data that was lost or misplaced between systems, but reconciliation of two exceptions correctly logged and correctly not counted in a summary report because they were alerts during processing, not errors that would be forwarded for review. These results do not present a significant deficiency in the ability of MDHHS to review the detailed exceptions. Also, these 2 records are insignificant when compared to the 11.6 million records processed in the 85 sampled files (0.000001 percent). Therefore, the current controls are reasonable to ensure that data processed from the source system to the receiving system is processed accurately, completely, and timely. Planned Corrective Action DTMB disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Nathan Buckwalter, DTMB

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic monitoring procedures to verify record completeness and compliance. d. Implement scheduled internal reviews and standardized checklists. e. Assign specific responsibilities to Human Resources personnel for policy enforcement.

Assistance Listings number and name: Award numbers and years: Assistance Listings number and name: Award numbers and years: Federal agency: 21.023 COVID-19 - Emergency Rental Assistance Program 1505-0270, May 5, 2021 through September 30, 2025 23*019, May 5, 2021 through September 30, 2025 23*056, May 5, 2021 through September 30, 2025 23*064, May 5, 2021 through September 30, 2025 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds 1505-0271, March 3, 2021 through December 31, 2024 19418, May 31, 2023 through September 30, 2023 U.S. Department of the Treasury Name of contact person: Ken Walker, Director (Interim), Grants Management & Innovation; Art Cuarón, Director, Finance and Risk Management Anticipated completion date: June 30, 2026 Response: Concur. The Pima County Department of Grants Management & Innovation (GMI) acknowledges the finding related to noncompliance with federal reporting requirements for the Emergency Rental Assistance (ERA) and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs. We recognize the critical importance of maintaining accurate, complete, and well-documented reporting in accordance with federal regulations, and we are committed to addressing the deficiencies noted in this finding. GMI recently adjusted the scope and activities of one of its decisions to address this concern. The division’s new title is Monitoring, Analysis, and Performance (MAP) and its responsibility is to ensure that required reporting documentation is appropriately collected and retained and that related policies and procedures are up-to-date and followed. Corrective Actions Taken and Planned: 1. Documentation and Retention Procedures The Department has implemented a formalized process to ensure that all program reports are supported by comprehensive documentation. This includes: o Capturing and retaining system-generated reports, screenshots, and data queries used in the preparation of ERA and SLFRF quarterly submissions. Each grant specific folder contains subfolders for: • Relevant emails • Screenshots of uploaded information and portal submissions • A copy of the Departmental Approval Form (review form acknowledging the review and agreement to submit programmatic and financial reports into its respective portal.) • A downloaded PDF of the data submitted for the respective quarter. o Establishing a secure digital repository to store supporting documentation for each report, ensuring accessibility and retention in accordance with 2 CFR §200.334 and the County’s record retention policies. • Reporting Guidance • Compliance Supplements • Resources (programmatic and/or service codes, definitions, etc.) • Copies of raw data provided and coding scripts for applicable data sets. o Conducting periodic internal audits to verify documentation compliance. • The MAP Monitoring manager will oversee periodic internal audits for all federal grants. 2. Policy and Procedure Development The Department is finalizing written policies and procedures that establish clear internal controls over the federal reporting process. These policies will require: o A formal reconciliation process of reported expenditures against the County’s general ledger prior to submission. o An independent review and documented approval of all reports to ensure accuracy and compliance with federal guidelines. o Designated accountability roles within the reporting workflow, with approvals required at each stage. This includes electronic approvals within Amplifund and Workday. Amplifund is now the central repository of all grant documentation and Workday is the County’s system of financial records. 3. Training and Staff Development In response to staff turnover, which created institutional knowledge gaps, the Department has launched a training initiative to ensure all relevant personnel are familiar with ERA and SLFRF reporting requirements. Training covers: o Reporting timelines and content requirements, o Use of the U.S. Treasury’s reporting portals, and o Internal compliance expectations, including documentation standards and retention policies. The performance of staff assigned to these tasks will be monitored and corrective action, including re-training, will be taken to address any failures. 4. Reporting Calendar and Tracking Mechanism To improve timeliness and oversight, the Department has initiated a centralized reporting calendar and task-tracking system (Amplifund). This system: o Sends automated reminders of upcoming reporting deadlines, o Tracks task completion by staff, and o Tracks workflows 5. Coordination with Federal Grantor The Department is actively engaging with the U.S. Department of the Treasury to determine whether any corrections can be submitted for previously reported ERA and SLFRF data. U.S. Treasury staff has informed grantees that they are to correct mistakes made in a previous report in the current report. So, while federal guidance currently limits the ability to resubmit reports after the reporting deadline, the County is exploring whether exception-based resubmissions are permissible in cases of material reporting error. Conclusion The County is committed to enhancing and upholding best practice internal controls and fully aligning with federal grant requirements. Staff recognize the impact of these reporting deficiencies and are taking decisive steps to improve accountability and audit readiness across all federal programs. The corrective actions outlined above are designed to address the current finding and to mitigate similar risks for other grant programs administered by the County.

The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

The Board will establish procedures that will ensure compliance with guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200 for Special Education.

The District is aware of the importance of maintaining documentation that demonstrates expenditures charged to a program are allocable and allowable. The District will review existing procedures related to the review of temporary workers to ensure that documentation is available to demonstrate charges to programs comply with federal guidelines and regulations. The District also recognizes the importance of timely approval of time and effort in compliance with federal regulations. While the District does perform regular reconciliations of expenses to ensure allowability, the District will review and update procedures, as necessary, to continue to improve and document timely supervisory approvals after each bi-weekly payroll is processed in relation to finding 2024-01 in the District’s Report on Internal Controls and Compliance.

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the criteria for the reporting is changed forcing us to change our answers, we will keep better notes of what we changed, and why we changed it. Our final numbers were correct, and we spent the money out of the correct categories. Jennifer Mossburger, Title I coordinator, and I worked together on this reporting. We will continue to work together on the reporting for the federal grants. However, we will do a better job of documenting our work. Anticipated Completion Date: 3/3/2025

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All withdrawals will have the proper documentation (transcript request or withdrawal form) attached to the student record and the form will be dated within two weeks of the student enrollment end date. The forms must be signed by the parent and the principal. Title 1 Director will review for accuracy and completion of forms. Anticipated Completion Date: December 31, 2025

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)